Hogan v. Kurtz was a United States Supreme Court case that dealt with the issue of whether a state court had the authority to issue a writ of habeas corpus to a prisoner who was being held in a federal prison. The case arose when a prisoner, Hogan, was held in a federal prison in the state of Pennsylvania. Hogan sought a writ of habeas corpus from the state court, claiming that he was being held in violation of the Constitution. The state court granted the writ, and Hogan was released from prison. The federal government then appealed the decision to the Supreme Court, arguing that the state court did not have the authority to issue the writ of habeas corpus. The Supreme Court agreed with the federal government, ruling that the state court did not have the authority to issue the writ of habeas corpus. The Court held that the writ of habeas corpus was a federal power, and that the state court did not have the authority to issue the writ. The Court also held that the writ of habeas corpus could only be issued by a federal court.

Justice Field delivered the dissenting opinion in Hogan v. Kurtz, arguing that the majority's decision was incorrect and should be reversed. He argued that a contract between two parties is binding on both of them unless it has been modified or rescinded by mutual agreement, and he disagreed with the majority's conclusion that one party could unilaterally modify or rescind an existing contract without consent from the other party. Furthermore, Justice Field asserted that if a court were to allow such unilateral action then it would lead to uncertainty in contracts because any time either party wanted to change something they could do so without consulting their counterpart first. He concluded his dissent by stating that this type of behavior would create chaos in commercial transactions and therefore should not be allowed under law.